Data, data, data. The final rules for inpatient rehabilitation facilities (IRF) payment and the inpatient prospective payment system (IPPS) continue the Centers for Medicare and Medicaid Services' (CMS) effort to put teeth into its push for more quality reporting while offering a mix of payment increases and cuts.
In rules that aren't significantly different from what they were when proposed in April (IRF, IPPS), CMS is applying more pressure to make the shift to a system it describes as being "based on the quality, rather than the quantity of care [health care providers] give patients."
CMS issued fact sheets on both the IRF and IPPS final rules. Here's a quick rundown.
Inpatient Rehabilitation Facilities
Payment: CMS has updated payments in 2016 by 1.8%--about $135 million. No changes were made to facility-level adjustments, which remain frozen at 2014 levels.
The big takeaway: After several years of evaluation, CMS has finally created a standalone market basket for IRFs, which will in turn boost payments. The trade-off: substantially increased quality reporting requirements.
The exclusive IRF market basket will allow CMS to collect outcome measures required by the IMPACT Act, a law that seeks to standardize reporting across postacute care facilities. These measures, which initially will include data on pressure ulcer incidence, falls, and changes in patient function and cognitive function, will be expanded over time. CMS expects to publicly share IRF reporting data beginning in the fall of 2016.
Inpatient Prospective Payment System
Payment: Not surprisingly, it's complicated. Acute care hospitals that successfully participate in the quality reporting program and that are "meaningful" users of electronic health records would receive a .9% payment update. Hospitals that don't successfully participate in the quality reporting program face a one-fourth reduction in that update; facilities that are not meaningful users of EHRS would have their update reduced by one-half.
CMS is also continuing its penalties on high readmission rates. According to an article in Kaiser Health News, the majority of hospitals will face reductions based on 30-day readmission rates between 2011 and 2014. Other reductions include a potential 4.6% overall reduction for long-term care hospitals (LTCHs).
The big takeaway: Data and outcomes. CMS will update the hospital inpatient quality reporting program by adding 7 new measures in 2018 and 2019, and will increase the measures required in the value-based purchasing program. LTCHs will also be required to report the same postacute care measures that will be required of SNFs through the IMPACT Act.
APTA provided comments on both the IRF (.pdf) and IPPS (.pdf) proposed rules, and will develop summary highlights on the final rules in the coming weeks.
Skilled nursing facilities (SNFs) will see a Medicare rate increase next year, although it won't be quite as much as originally proposed by the Centers for Medicare and Medicaid Services (CMS). And while news about next year's payment adjustment almost always gets attention, some of the most notable parts of the new rule are more focused on the future beyond 2016, and what SNFs will be expected to do if they want to avoid penalties—or pursue incentives.
As for payments, the rule rolled out last week by CMS includes a rate increase of 1.2% for 2016, a bump that's down about $70 million from the 1.4% increase proposed earlier this year. Overall, CMS projects aggregate payments to increase by $430 million in 2016.
But the news isn't just about payments. Other parts of the rule are worth noting because of the ways they will change reporting requirements over the next few years. These changes apply to 3 main areas:
The reporting changes are designed to comply with specific mandates in the Affordable Care Act, the Protecting Access to Medicare Act, and the IMPACT Act, but CMS believes the combined effect of the new requirements will be to move the ball closer to the goal of value-based payments. "The final rule includes policies that advance that vision and support building a health care system that delivers better care, spends health care dollars more wisely, and results in healthier people," CMS states in a fact sheet on the changes as proposed in April.
APTA submitted comments on the proposed rule (.pdf), and will develop a summary and highlights guide during the coming weeks.
Internationally educated physical therapists (PTs) will soon be able to get up to speed on crucial areas of the US health care system, thanks to a collaborative effort to develop an online course that aims to smooth the transition into practice as a licensed PT in the US.
APTA, the Federation of State Boards of Physical Therapy (FSBPT), the Foreign Credentialing Commission on Physical Therapy (FCCPT), and APTA's Section on Health Policy and Administration (known as HPA: The Catalyst), recently announced that Duke University has been selected to develop, run, and administer an online course that covers the health care delivery system in the US. According to a news release from APTA and its project partners, the course is designed to help PTs educated and trained outside the US "overcome hurdles resulting from cultural differences and achieve a smoother and quicker transition" to stateside practice.
The joint effort to establish the course began over a year ago, led by a multi-organization project team with members from each of the participating entities.
Aspects of the American health care system that will be covered in the 10-module course will include the role of federal and state governments, Medicare and Medicaid basics, the private insurance system, proper use and supervision of support personnel, ethics and integrity in practice, cultural competence, billing, and direct access.
The course will be made available online through Duke University. Participants will receive college credit for completing all 10 modules.
Duke was selected from among 10 candidates that had submitted proposals.
"This is a fantastic example of what can be achieved when leading groups in health care collaborate to achieve a common goal," said APTA President Sharon L. Dunn, PT, PhD, OCS, in the statement. "We are excited to get the ball rolling."
When it arrived as signed legislation 50 years ago, Medicare and Medicaid was far from the system we know today—especially when it comes to physical therapy. APTA is marking the program's half-century birthday by highlighting how its evolution affected the profession, and vice-versa.
Just in time for the July 30 anniversary of Medicare and Medicaid, the association has released an infographic (.pdf) that lays out the timeline for physical therapy's involvement in a program that covers an estimated 124,000,000 people (55 million via Medicare and 69 million through Medicaid). The program, controversial at the time of its implementation, now is credited with increasing life expectancy and reducing poverty in the United States.
Today's Medicare and Medicaid are significantly different from their original forms. Medicaid, for example, was tied to welfare, and Medicare didn't cover prescription drugs. Initially, private insurance played a far less prominent role than it does today, and hospitals and nursing homes were racially segregated (something Medicare and Medicaid helped to eliminate).
The physical therapy profession became part of this evolution in 1968 and has remained integral to the program ever since. Like almost every other element connected to Medicare and Medicaid, however, the relationship between the programs and physical therapy has changed over time.
It's a relationship that, judging from the APTA timeline, has had its share of ups and downs. But it generally has trended toward increased patient access to physical therapist services. Among the notable developments listed in the infographic:
Many more details appear on the timeline, including more recent developments such as the repeal of the flawed sustainable growth rate formula and the signing into law of the Improving Medicare Post-Acute Care Transformation (IMPACT) Act.
"It's nearly impossible to underestimate the effects Medicare and Medicaid have had on the overall population health of the United States," said APTA President Sharon L. Dunn, PT, PhD, OCS. "The physical therapy profession has had a relationship with these programs for nearly as long as they've existed. We should take pride in the ways our commitment to patient health and transformation has, in turn, helped Medicare and Medicaid evolve."
Interested in more history and real-world accounts of the ways in which Medicare and Medicaid have made a difference in people's lives? Check out the CMS webpage devoted to the anniversary.
In addition to its annual payment update, the recently released Centers for Medicare and Medicaid Services (CMS) proposed rule for the 2016 Medicare home health prospective payment system (HH PPS) includes policy changes for home health agencies and a new value-based home health model to encourage quality.
Below are some key highlights of the rule that impact physical therapists and physical therapist assistants. The association will prepare a more-detailed summary in the coming days and post it to APTA's website.
Payment Policy. Taking into account all the policy changes, CMS estimates that overall Medicare payments to home health agencies will be reduced by $350 million or 1.8% in 2016 compared with 2015. This decrease reflects a 2.9% market-basket update and 0.6 percentage point cut for productivity, which is mandated by the Affordable Care Act. The rule also includes a 1.72% cut in each of 2016 and 2017 to account for estimated case mix growth 2012-2014, which the agency believes is unrelated to patient acuity, and a scheduled -2.5% rebasing adjustment, the third of a 4-year phase-in. In addition, the proposed 2016 national, standardized 60-day episode payment rate would be $2,938.37. If a home health agency (HHA) does not submit the required quality data, that rate would drop by 2% to $2,880.92.
Home Health Quality Reporting Program. CMS will add 1 standardized cross-setting measure to the Home Health Quality Reporting Program for 2015, as required by the IMPACT Act of 2014. The law requires HHAs, skilled nursing facilities, inpatient rehabilitation facilities, and long-term care hospitals to submit standardized patient assessment data and standardized data on quality measures and recourse use. The proposed new measure, the National Quality Forum (NQF)-endorsed measure: Percent of Residents or Patients with Pressure Ulcers That Are New or Worsened (Short Stay) (NQF #0678), addresses changes in skin integrity. Also new for 2016, all HHAs will need to submit both admission and discharge OASIS assessments for at least 70% of all patients whose episodes of care occurred during the reporting period starting July 1, 2015. The threshold will increase by 10% in each of 2016 and 2017 to reach 90%.
Home Health Value-Based Payment Model. HHAs in 9 states will participate in a new value-based payment model beginning January 1, 2016. These HHAs will receive a payment increase or reduction in a future year based on quality performance in the designated earlier year, and CMS projects an estimated $380 million in total savings 2018-2022 from reductions in unnecessary hospitalizations and skilled nursing facility usage. The states, chosen randomly from within designated geographic groupings, are Arizona, Florida, Iowa, Maryland, Massachusetts, Nebraska, North Carolina, Tennessee, and Washington. Among the details of the program:
In the first physician fee schedule rule to come out since the repeal of the sustainable growth rate formula, the Centers for Medicare and Medicaid Services (CMS) proposes revisions to payment policies, establishes 2016 payment rates for Medicare-billed services, and updates quality provisions. The rule also begins implementation of the new merit-based incentive payment system, applicable for now to physicians and other designated providers (not physical therapists) only.
How will the rule impact physical therapists (PTs) and physical therapist assistants (PTAs)? Below are some key highlights from APTA's initial look at the proposed rule. The association will prepare a more detailed summary in the coming days and post to APTA's website.
2016 Payment Rates. The payment rate for physical therapy services is estimated to increase approximately 0.5%. This is based on:
Misvalued Codes. Ten CPT codes that PTs typically report were identified by CMS for review to determine if they are "misvalued" and need to be updated based on possible changes in physician work and direct practice expense inputs, as these codes haven't been reviewed since 2009 or earlier. The codes are 97032 (electrical stimulation), 97035 (ultrasound therapy), 97110 (therapeutic exercises), 97112 (neuromuscular reeducation), 97113 (aquatic therapy), 97116 (gait training), 97140 (manual therapy), 97530 (therapeutic activities), 97535 (self-care management training), G0283 (electrical stimulation other than wound). They are among 118 total "high expenditure" codes (with Medicare allowed charges of $10 million or more) that CMS identified for review, with a target of a 1% reduction in expenditures for misvalued codes in 2016.
Quality Provisions. Reporting requirements and the measures that PTs report in 2016 under the PQRS program will be largely unchanged from 2015. PTs who don't successfully participate in PQRS in 2016 will face a 2.0% reduction in payment in 2018. In other quality reporting provisions:
Physician Self-Referral. CMS proposes some major provisions related to the physician self-referral law (ie, Stark Law) and its exceptions. CMS states the purpose of these proposals is "to accommodate delivery and payment system reform, to reduce burden, and to facilitate compliance," and "to expand access to needed health care services."
APTA will submit comments on the proposal, which are due September 8.
Did you know that Medicare payments will be increased by 0.5% effective July 1? Stay on top of the new rates with APTA's MPPR calculator—an outpatient therapy claim pricer that can help you determine your payment for services.
Tip: Be sure to click on the calculator that corresponds to the date service was provided.
Spring is gone, summer's here, and the US Centers for Medicare and Medicaid (CMS) just keeps on churning out more proposed and final rules that can have a big impact on physical therapists (PTs) and physical therapist assistants (PTAs). Sometimes the changes will be felt directly by PTs and PTAs; sometimes the changes affect how employers will operate; sometimes the changes have to do with the ways beneficiaries interact with the systems.
The regulatory affairs staff at APTA keeps a close eye on all of the rulemaking and creates detailed resources that can keep you up to speed. It's all part of an effort to untangle rules that can seem dizzingly complex—but should not be ignored.
Here are 5 rules you should know about—4 proposed and 1 final—and what APTA offers for a more detailed take.
Acute care hospitals and long-term care hospitals (proposed rule)
The IMPACT Act signed into law last year is sparking some significant changes around the kind of data long-term care facilities gather and report, with emphasis on standardized quality reporting across the different types of postacute care facilities—long-term care hospitals, inpatient rehabilitation facilities, skilled nursing facilities, and home health agencies. CMS estimates that Medicare spending on inpatient hospital services will increase by about $120 million in FY 2016.Available from APTA: summary and highlights, comments to CMS
Skilled nursing facility (SNF) prospective payment system (proposed rule)
CMS is proposing an increase in payments to SNFs, and also implementing a SNF quality reporting program by 2018. Again, the IMPACT Act plays a big role in the proposal, with requirements for new quality measures for the SNF quality reporting program. Also worth noting—new rules on mandatory reporting about staffing, including hours worked and employee turnover.Available from APTA: summary and highlights, comments to CMS
Inpatient rehabilitation facility (IRF) prospective payment system (proposed rule)
IRFs will receive an average overall estimated increase of 1.7% in 2016. Like other postacute care settings, IRFs would be subject to increased quality reporting requirements for quality domains identified in the IMPACT Act. CMS also proposes 4 additional functional status measures for IRFs.Available from APTA: summary and highlights, comments to CMS
Medicaid Managed Care Organizations (proposed rule)
The first major change proposed to Medicaid in a dozen years, the rule is described by Health Affairs as "a defining moment" for the program. The rule takes aim at how Medicaid managed care plans can market to consumers, and how the plans can be integrated with the health care exchanges developed through the Patient Protection and Affordable Care Act (ACA). The proposal, which also affects the Children's Health Insurance Plan (CHiP), would increase program integrity and quality improvement requirements.Available from APTA: summary and highlights (comments under development)
Medicare Accountable Care Organizations (ACO) (final rule)
The final CMS rule on Medicare ACOs includes more flexibility for the care networks, which now number nearly 400 and serve an estimated 7 million beneficiaries. Among other changes, the rule opens up a "third option" for ACOs that involves taking on more risk in exchange for the potential to keep more money linked to savings. The new rule also opens up the possibility for ACOs to avoid penalties beyond the 3-year timeframe previously established by CMS,Available from APTA: summary and highlights of final rule
Plus: Stay tuned for one of the year's most-anticipated rules—the CMS proposal for next year's physician fee schedule, likely to be released on or around July 1. Also due to drop soon: proposed rules on home health and outpatient hospitals. APTA will review all proposed rules and create a highlights resource, as well provide comments to CMS.
A bill that would help some physical therapists (PTs) in private practice improve continuity of care has been approved by the US Senate Finance Committee, and could be up for a vote on the Senate floor soon. Known as the Prevent Interruptions in Physical Therapy Act (S. 313), the legislation would extend so-called "locum tenens" provisions to PTs in rural and underserved areas—a change strongly supported by APTA and its Private Practice Section, and one of the advocacy areas targeted at the recent PT Day on Capitol Hill and at the joint APTA/Private Practice Section (PPS) legislative fly-in earlier this year.
The bill now being discussed would allow a PT to bring in another licensed physical therapist to treat Medicare patients and bill Medicare through the practice provider number during temporary absences for illness, pregnancy, vacation, or continuing medical education. To limit budgetary impact, the legislation was amended to allow locum tenens for PTs only in non-Metropolitan Statistical Areas, Medically Underserved Areas (MUAs), and Health Professions Shortage Areas (HPSAs) as defined by the US Department of Health and Human Services.
A companion bill has been introduced in the US House of Representatives (H.R. 556). If the bill is approved by Congress and signed into law, private practice PTs in these designated areas would join doctors of medicine, osteopathy, dental surgery, podiatric medicine, optometry, and chiropractic on the list of locum tenens providers.
The bill was introduced by Sens Charles Grassley (R-IA) and Bob Casey (D-PA) in the Senate; Reps Gus Biliraikis (R-FL) and Ben Ray Lujan (D-NM) are leading the House efforts. APTA and PPS collaborated on pressing for the legislation, which APTA identified as a goal of its public policy priorities.
During the Senate Finance Committee hearing on the bill, Grassley stated that "physical therapists provide important and necessary services to their patients, and should have the ability to ensure continuous care for their patients when a period of short-term leave is needed." Casey added that he and other supporters of locum tenens for PTs "want to keep working until these arrangements are allowed nationwide."
Sen Charles Grassley (R-IA)
speaks in favor of locum tenens for PTs.
"This is a much-needed correction that will have a significant impact on the care some PTs can provide their patients and clients," said Terence Brown, PT, PPS president. "We're extremely pleased with the strong possibility that small or solo physical therapy practices in rural and underserved areas will soon be able to avoid interruptions in care that can truly impact patient progress."
APTA President Sharon Dunn, PT, PhD, OCS, called the news of the bill's advance a "definite win for physical therapy," saying the success so far is due in large part to the combined efforts of APTA, PPS, and individual members who contacted their legislators—and even showed up in lawmakers' offices in-person during PT Day on Capitol Hill, held June 4.
"The push for locum tenens is part of larger efforts by APTA and its members to truly transform patient access to care," Dunn said. "We are hopeful for passage of this legislation and, with it, the reduction of an unnecessary regulatory barrier. It's part of a bigger picture that our members see clearly, and we're taking that vision to lawmakers."
APTA will monitor the progress of the bills and post updates to its locum tenens webpage. Resources on the website include a podcast on the importance of this legislation and information on how PTs can get involved in advocating for its passage.
The following members were elected to APTA's Board of Directors and Nominating Committee on Monday at the House of Delegates in National Harbor, Maryland.
Sharon L. Dunn, PT, PhD, OCS, was elected president.
Lisa K. Saladin, PT, PhD, FASAHP, was elected vice president.
Jeanine M. Gunn, PT, DPT, was reelected director, and Susan A. Appling, PT, DPT, PhD, OCS, and Robert H. Rowe, PT, DPT, DMT, MHS, FAAOMPT, were elected director.
Scott Euype, PT, DPT, MHS, OCS, was elected to the Nominating Committee.
These terms become effective at the close of the House of Delegates on Wednesday.
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